Privacy Policy

1. INTRODUCTION

This privacy policy provides you with details of how we collect and  process your personal data through your use of our site www.helengailey.com  and www.rebuild2win.com or any subdomains including any information you may provide to us when  you purchase a product or service, sign up to our email list or take  part in a prize draw or competition.
By providing us with your data, you warrant to us that you are over 13 years of age.
HCGConsulting is the data controller and we are responsible for your  personal data (referred to as “we”, “us” or “our” in this privacy  policy).
 
If you have any questions about this privacy policy, please contact us by using the details set out below.
Contact Details
Full name of legal entity: HCGConsulting
Email address: info@helengailey.com
Postal address: HCGConsulting, Chemin du Vernay 72, BOX50, 1196 Gland Switzerland
It is very important that the information we hold about you is  accurate and up to date. Please let us know if at any time your personal  information changes by emailing us at info@helengailey.com or updating your  settings in our preference center.

2. WHAT DATA DO WE COLLECT ABOUT YOU

Personal data means any information capable of identifying an individual. It does not include anonymised data.
We may process the following categories of personal data about you:
  • Communication Data that includes any communication  that you send to us whether that be through the contact form on our  website, through email, text, social media messaging, social media  posting or any other communication that you send us. We process this  data for the purposes of communicating with you, for record keeping and  for the establishment, pursuance or defence of legal claims. Our lawful  ground for this processing is our legitimate interests which in this  case are to reply to communications sent to us, to keep records and to  establish, pursue or defend legal claims.
  • Customer Data that includes data relating to any  purchases of goods and/or services such as your name, title, billing  address, delivery address email address, phone number, contact details,  purchase details and your card details. We process this data to supply  the goods and/or services you have purchased and to keep records of such  transactions. Our lawful ground for this processing is the performance  of a contract between you and us and/or taking steps at your request to  enter into such a contract.
  • User Data that includes data about how you use our  website and any online services together with any data that you post for  publication on our website or through other online services. We process  this data to operate our website and ensure relevant content is  provided to you, to ensure the security of our website, to maintain  back- ups of our website and/or databases and to enable publication and  administration of our website, other online services and business. Our  lawful ground for this processing is our legitimate interests which in  this case are to enable us to properly administer our website and our  business.
  • Technical Data that includes data about your use of  our website and online services such as your IP address, your login  data, details about your browser, length of visit to pages on our  website, page views and navigation paths, details about the number of  times you use our website, time zone settings and other technology on  the devices you use to access our website. The source of this data is  from our analytics tracking system. We process this data to analyse your  use of our website and other online services, to administer and protect  our business and website, to deliver relevant website content and  advertisements to you and to understand the effectiveness of our  advertising. Our lawful ground for this processing is our legitimate  interests which in this case are to enable us to properly administer our  website and our business and to grow our business and to decide our  marketing strategy.
  • Marketing Data that includes data about your  preferences in receiving marketing from us and our third parties and  your communication preferences. We process this data to enable you to  partake in our promotions such as competitions, prize draws and free  giveaways, to deliver relevant website content and advertisements to you  and measure or understand the effectiveness of this advertising. Our  lawful ground for this processing is our legitimate interests which in  this case are to study how customers use our products/services, to  develop them, to grow our business and to decide our marketing strategy.
We may use Customer Data, User Data, Technical Data and Marketing  Data to deliver relevant website content and advertisements to you  (including Facebook adverts or other display advertisements) and to  measure or understand the effectiveness of the advertising we serve you.  Our lawful ground for this processing is legitimate interests which is  to grow our business. We may also use such data to send other marketing  communications to you about relevant products and services, such as  online courses; books; live broadcast trainings such as webinars; live  events and conferences; coaching and mentoring services. Our lawful  ground for this processing is either consent or legitimate interests  (namely to grow our business).
We do not collect any Sensitive Data about you.  Sensitive data refers to data that includes details about your race or  ethnicity, religious or philosophical beliefs, sex life, sexual  orientation, political opinions, trade union membership, information  about your health and genetic and biometric data. We do not collect any  information about criminal convictions and offences.
Where we are required to collect personal data by law, or under the  terms of the contract between us and you do not provide us with that  data when requested, we may not be able to perform the contract (for  example, to deliver goods or services to you). If you don’t provide us  with the requested data, we may have to cancel a product or service you  have ordered but if we do, we will notify you at the time.
We will only use your personal data for a purpose it was collected  for or a reasonably compatible purpose if necessary. In case we need to  use your details for an unrelated new purpose we will let you know and  explain the legal grounds for processing.
We may process your personal data without your knowledge or consent where this is required or permitted by law.
We do not carry out automated decision making or any type of automated profiling.

3. HOW WE COLLECT YOUR PERSONAL DATA

We may collect data about you by you providing the data directly to  us (for example by filling in forms on our site or by sending us  emails). We may automatically collect certain data from you as you use  our website by using cookies and similar technologies. Please see our cookie policy for more details about this.
We may receive data from third parties such as analytics providers  such as Google based outside the EU, advertising networks such as  Facebook based outside the EU, such as search information providers such  as Google based outside the EU, providers of technical, payment and  delivery services, such as data brokers or aggregators.
We may also receive data from publicly available sources such as Companies House and the Electoral Register.

4. MARKETING COMMUNICATIONS

Our lawful ground of processing your personal data to send you  marketing communications is either your consent or our legitimate  interests (namely to grow our business).
Under the Privacy and Electronic Communications Regulations, we may  send you marketing communications from us if (i) you made a purchase or  asked for information from us about our goods or services or (ii) you  agreed to receive marketing communications and in each case you have not  opted out of receiving such communications since. Under these  regulations, if you are a limited company, we may send you marketing  emails without your consent. However, you can still opt out of receiving  marketing emails from us at any time.
Before we share your personal data with any third party for their own marketing purposes we will get your express consent.
You can ask us or third parties to stop sending you marketing  communications at any time by following the opt-out links in every email  sent to you OR by emailing us at info@helengailey.com at any time.
If you opt out of receiving marketing communications this opt-out  does not apply to personal data provided as a result of other  transactions, such as purchases, orders etc.

5. DISCLOSURES OF YOUR PERSONAL DATA

We may have to share your personal data with the parties set out below:
  • Service providers who provide IT and system administration services.
  • Professional advisers including lawyers, bankers, auditors and insurers
  • Government bodies that require us to report processing activities.
  • Third parties such as copywriters, customer support and virtual assistants.
  • Third parties to whom we sell, transfer, or merge parts of our business or our assets.
We require all third parties to whom we transfer your data to respect  the security of your personal data and to treat it in accordance with  the law. We only allow such third parties to process your personal data  for specified purposes and in accordance with our instructions.

6. INTERNATIONAL TRANSFERS

Countries outside of the European Economic Area (EEA) do not always  offer the same levels of protection to your personal data, so European  law has prohibited transfers of personal data outside of the EEA unless  the transfer meets certain criteria.
Many of our third parties service providers are based outside the  European Economic Area (EEA) so their processing of your personal data  will involve a transfer of data outside the EEA.
Whenever we transfer your personal data out of the EEA, we do our  best to ensure a similar degree of security of data by ensuring at least  one of the following safeguards is implemented:
We will only transfer your personal data to countries that have been  deemed to provide an adequate level of protection for personal data by  the European Commission; or
Where we use certain service providers, we may use specific contracts or  codes of conduct or certification mechanisms approved by the European  Commission which give personal data the same protection it has in  Europe; or
Where we use providers based in the United States, we may transfer data  to them if they are part of the EU-US Privacy Shield which requires them  to provide similar protection to personal data shared between the  Europe and the US.
If none of the above safeguards is available, we may request your  explicit consent to the specific transfer. You will have the right to  withdraw this consent at any time.

7. DATA SECURITY

We have put in place appropriate security measures to prevent your  personal data from being accidentally lost, used or accessed in an  unauthorised way, altered or disclosed. In addition, we limit access to  your personal data to those employees, agents, contractors and other  third parties who have a business need to know such data. They will only  process your personal data on our instructions and they are subject to a  duty of confidentiality.
We have put in place procedures to deal with any suspected personal  data breach and will notify you and any applicable regulator of a breach  where we are legally required to do so.

8. DATA RETENTION

We will only retain your personal data for as long as necessary to  fulfil the purposes we collected it for, including for the purposes of  satisfying any legal, accounting, or reporting requirements.
When deciding what the correct time is to keep the data for we look  at its amount, nature and sensitivity, potential risk of harm from  unauthorised use or disclosure, the processing purposes, if these can be  achieved by other means and legal requirements.
For tax purposes the law requires us to keep basic information about  our customers (including Contact, Identity, Business Communications,  Financial and Transaction Data) for ten years after they stop being  customers.
In some circumstances we may anonymise your personal data for  research or statistical purposes in which case we may use this  information indefinitely without further notice to you.

9. YOUR LEGAL RIGHTS

Under data protection laws you have rights in relation to your  personal data that include the right to request access, correction,  erasure, restriction, transfer, to object to processing, to portability  of data and (where the lawful ground of processing is consent) to  withdraw consent.
You can read more about these rights here.
If you wish to exercise any of the rights set out above, please email us at info@helengailey.com.
You will not have to pay a fee to access your personal data (or to  exercise any of the other rights). However, we may charge a reasonable  fee if your request is clearly unfounded, repetitive or excessive or  refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us  confirm your identity and ensure your right to access your personal data  (or to exercise any of your other rights). This is a security measure  to ensure that personal data is not disclosed to any person who has no  right to receive it. We may also contact you to ask you for further  information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month.  Occasionally it may take us longer than a month if your request is  particularly complex or you have made a number of requests. In this  case, we will notify you.
If you are not happy with any aspect of how we collect and use your  data, you have the right to complain to your local supervisory authority  for data protection issues. Read more about these rights here: https://www.eugdpr.org/. We would be grateful if you would contact us first if you do have a complaint so that we can try to resolve it for you.

10. THIRD-PARTY LINKS

This website may include links to third-party websites, plug-ins and  applications. Clicking on those links or enabling those connections may  allow third parties to collect or share data about you. We do not  control these third-party websites and are not responsible for their  privacy statements. When you leave our website, we encourage you to read  the privacy policy of every website you visit.

11. COOKIES

You can set your browser to refuse all or some browser cookies, or to  alert you when websites set or access cookies. If you disable or refuse  cookies, please note that some parts of this website may become  inaccessible or not function properly. For more information about the  cookies we use, please see our cookie policy.

12. CHANGES TO OUR PRIVACY POLICY

We reserve the right to update our privacy policy at any time. We  will notify you over email if you are subscribed to our list and by  updating the date of our notice here on this page.
Last Updated: May, 2018